is taken away, but no replacement for the administration of these cases have been provided. It is likely that even more applicants will be rejected at local office level. In our experience, local offices routinely refuse to assist the following categories of persons in accessing late birth registration: • • • Persons born abroad to South African citizens who do not have a birth record from the birth country Persons who are unable to show a letter from the school they attended and/or are unable to produce a clinic card or maternity certificate from the clinic in which they were born. Where applicants are not able to provide a witness to their birth, they are routinely turned away without any alternative solution being proffered. Persons who are unable to produce a witness that is a South African citizen. Where the applicant is not able to provide a citizen witness, he or she is routinely turned away. This requirement does not facilitate and actually frustrates one of the main goals of the Births and Deaths Registration Act, which is registration of all births in the Republic. In some cases the only living witness to a person's birth in the Republic may not be a South African citizen. There is also the troubling, discriminatory suggestion by this policy that citizens are more credible witnesses than non-citizens. Assisting clients to access LRB The Regulations to the Births and Deaths Registration Act prescribe procedures for a late registration of birth. Where the procedure was previously more flexible and discretionary, the following requirements are listed in regulation 4 (regulation 5 which applies to children registered after one year requires basically the same and is not more discretionary): 4 Late registration of birth of children of South African citizens (1) A notice of birth given later than 30 days after the birth but before the child is older than one year, shall be given in accordance with subregulation (3). (2) Where both parents of a child whose birth is sought to be registered in terms of subregulation (1) are deceased, the notice of birth must be given by the next-of-kin or legal guardian of the child. (3) A notice of birth referred to in subregulation (1) must be given by, where possible, both parents to the Director-General on Form DHA-24/ LRB illustrated in Annexure 1B and be accompanied by – (a) proof of birth on Form DHA-24/PB illustrated in Annexure 1D attested to by a medical practitioner who – (i) attended to the birth; or (ii) examined the mother or the child after the birth of the child; (b) an affidavit attested to by a South African citizen who witnessed the birth of the child where the birth occurred at a place other than a health institution on Form of DHA-24/PBA illustrated in Annexure 1E; (c) biometrics, in the form of a palm, foot or fingerprint, of the child whose birth is sought to be registered in the appropriate space on Form DHA-24 illustrated in Annexure 1A; (d) fingerprints of the parents, which shall be verified online against the national population register: Provided that where the fingerprints cannot be verified online, the full set of fingerprints of the parents shall be taken on form DHA-24/A illustrated in Annexure 1C; 72 Promoting citizenship and preventing statelessness in South Africa: A practitioner’s guide